I- Company Profile

Del Monte Philippines, Inc. (DMPI) is a leading producer, distributor and marketer of
premium quality, healthy food and beverage products. It has been in operation in the
Philippines for 97 years and is a market leader in the packaged pineapple and mixed
fruit, ready-to-drink juices (excluding stand-up-pouches), tomato sauce and spaghetti
sauce categories.

DMPI has the rights to the Del Monte trademark for the Philippines for processed
products. It also sells products under the well-known group brands of S&W, Contadina
and Today’s. More than half of DMPI’s sales are in the Philippines and the balance in
the international market.

II- Objectives of the code of ethical conduct

This Code of Business Conduct and Ethics (“Code”) of Del Monte Philippines, Inc.
(DMPI) has been established to encourage its officers and other employees to observe
the highest standards of business and personal ethics in the conduct of their duties and
responsibilities. As representatives of the Company, they must practice honesty and
integrity and strictly comply with all applicable laws, rules and regulations. In its pursuit
of good corporate governance, the Company encourages its officers, employees,
contractors, and suppliers to provide information that evidences unsafe, unlawful,
unethical, fraudulent or wasteful practices.

This Code of Business Conduct and Ethics (“Code”) of Del Monte Philippines, Inc.
(DMPI) shall conduct their businesses in a manner which, in all reasonable
circumstances, is above reproach. In line with this, the Company expects from all
officers and employees the highest standards of business and personal ethics.
Company employees must act with the utmost fairness and according to the highest
moral principles when dealing with the Company’s stakeholders – co ‐employees,
customers, suppliers, shareholders, the government and surrounding communitie
III- Ethical principles adapted by the Company

Del Monte Philippines Inc. is committed to the highest standards of corporate

governance as it supports the principles of openness, integrity, and accountability,
Fairness and Transparency are advocated by the Philippine Stock Exchange, Inc.
(PSE) and the Securities and Exchange Commission of the Philippines (SEC). The
Company aims to:

A. The Company shall value its employees and recognize their important role in the
successful conduct of its business.

B. The Company shall cultivate among its employees a culture of integrity and
excellence
and a sense of accountability, transparency and urgency.

C. The Company shall continually provide high quality products and best in class
service to
its customers. It shall endeavor to be the world’s best source of processed pineapple,
tropical fruit and other products in terms of quality, supply reliability, customer service
and price competitiveness.

D. The Company acknowledges the importance of building a sound relationship with its
suppliers. Accordingly, the Company shall conduct business with all customers on the
basis of integrity, mutual interest and fairness.

E. The Company shall endeavor to comply with all laws, rules and regulations that
govern
its business. It shall be guided by the principles of ethical conduct when dealing with the
government, its agencies and instrumentalists.

F. The Company shall respect the laws of all countries where it conducts business.
G. The Company shall promote honesty and integrity in dealing with government
agencies
and instrumentalists. Company employees are prohibited from influencing the
government’s judgment or conduct through the giving of bribes or other unlawful
inducements.

H. The Company shall not engage in partisan politics and shall prohibit its employees
from using the Company’s name and/or resources in campaigning for or against
particular candidates during elections.

IV- List of instances of unethical acts

A Del Monte Philippines, Inc. (Del Monte) categorically denies a report issued by Global
Witness implying inappropriate business behavior.

B. The ad, which has been seen as a symbol of casual sexism in the United States
during the 1950s, is sometimes mistakenly attributed to Del Monte.

C. Global Witness report accuses food and beverage company of 'inappropriate' ties
with a landlord accused of violence.

D. Del Monte is accused of links to violence against indigenous people in the

Philippines.

V. Process for identifying the threats or risks of unethical acts

A conflict or appearance of conflict of interest may arise in many ways. There are
conflict situations that are absolutely prohibited principally because they prejudice the
interest of the Company. There are also situations where a conflict or appearance of
conflict is expressly allowed because it is either harmless or beneficial to the Company.
Lastly, there are certain conflict situations the impact of which on the Company is not
immediately identifiable and will therefore have to be referred to the Audit Committee for
resolution.

VI. Process for determining whether the threats are significant

A In dealing with the news media and the public in general, the Company shall project
a positive image based on truth.

B. All terms and conditions of employment, including but not limited to, hiring, pay,
promotion, and termination must be based on an individual’s ability and willingness to
do the job. Suppliers must not discriminate in hiring and employment practices based on
race, color, gender, nationality, religion, age, sexual orientation, social or ethnic origin,
disability, maternity, marital status, political affiliation or union membership.

C. All workers shall be treated with dignity and respect. Employees, Suppliers or
contractors shall recognize the right to a workplace free of harassment and shall not
engage in or permit corporal punishment or any other form of physical or psychological
coercion including threats of violence or sexual harassment. Employees must be free to
leave their employers after giving reasonable notice and are not required to lodge
deposits or payment with their employers.

VII. Resolving ethical conflicts

When unsure of how to proceed in a specific circumstance pertaining to a topic covered

by the Code, any director, officer, or employee is encouraged to get in touch with the
Corporate Governance Office.

VIII. Reporting of ethical issues and concerns

Unethical behavior in the workplace runs the gamut from pilfering pens to spreading
false rumors to embezzlement and harassment. Reporting unethical conduct happening
at work is the right thing to do. Review the Company handbook and Consult the
organization’s rules and policies to determine if sketchy behavior is prohibited. Reports
of unethical behavior are more likely to be taken seriously if there is hand knowledge of
a clear policy violation.

IX. Sanctions for violations of the code of ethical conduct

As a condition of doing business with Del Monte, employees, suppliers and contractors
must comply with this Code of Conduct. If Del Monte determines that any employees,
suppliers and contractors has violated this Code, Del Monte may at its discretion either
terminate its business relationship and/or require the supplier to implement a corrective
action plan. Employers, Suppliers, and Contractors shall promptly notify Del Monte of
any significant criminal or civil legal actions or any fines or sanctions brought against
them which relate to any requirements set out in this Code.

X. Approval of the code of ethical conduct

This Code of Conduct and Business Ethics Policy applies at all locations owned, leased,
managed, or operated by Fresh Del Monte Produce Inc.